festivities for the plant were modest, the best days of this facility
are clearly behind it. Borg Warner, the firm that owned the plant for
over half the century, moved its automotive operations to a more modern
facility by the Tompkins Regional Airport in the early 1980s and sold
the remaining operations to Emerson in 1983. The number of employees has
been dropping, and it was announced in 2007 that the headquarters and
higher-level and sales employees would be moved out. Still, the plant
and its owners have made contributions to our community beyond the wages
paid to employees. In the summer of 2009, it was announced that the entire facility would be shut down by the end of September 2010. This schedule stretched to the end of 2010, but the once-busy plant now is idle and abandoned.
Remaining machinery and tools were auctioned off and taken away early in the year 2011. After reports of open doors and lack of appropriate security, damaged doors were repaired and facility guards began taking a strict attitude toward all who came near the plant grounds. Even neighbors walking dogs were threatened with arrest.
Any signs of interest in buying the site have been kept secret. Groups have expressed public interest in discussing what could be done on this large parcel of land, but seemingly everything hinges on the willingness of a buyer to accept the challenges of remediation, even if most costs are paid by the current owners. The downhill section of the site (with most of the buildings) is in the City of Ithaca. The larger uphill section is in the Town of Ithaca. How those jurisdictions will coordinate their efforts to allow new uses for the site, remains to be seen.
Karen Cahill, Project Manager from the Syracuse DEC office, e-mailed this report in early June 2011, regarding the Fire Water Reservoir (FWR) and other cleanup/encapsulation plans:
* FWR pre-design report submission to NYSDEC. End of June 2011
* FWR remedial action work (as warranted based on pre-design investigations). September 2011
* Former 507 Degreaser pre-design report submission to NYSDEC * End of June 2011; Pilot Test August 2011; Remedy Fall 2011
* Cap installation outside former 507 Degreaser Area. Fall 2011
* Final remedial action report submission for all 3 efforts. Early 2012
ONSITE ACTIVITY REPORTS
The FWR "Pre-Design" Report, dated June 30, 2011, has been released. It describes the decommissioning of the infamous FWR, and includes pictures of the removal of the liner, installation of test points, and excavation in and around the FWR. While the FWR is empty and the levels of TCE are lower immediately around the FWR, the levels in the downgradient groundwater test wells are still very high. There are also problems with oil and petroleum products seeping - the DPE system is not designed to handle these.
The full report is here. The full report is over 16MB. Smaller files with report sections are available as well:
Text Figures Tables Site Photographs Waste Maintenance Boring Logs and Well Diagrams Geophysical Survey
Progress Report #4 for the onsite "Dual Phase Extraction" system was released on August 9, 2011, covering the operations during July-December 2010. The short summary of the report is this:
During the reporting period, approximately 4.1 pounds (lbs) of volatile organic compounds (VOCs) were removed from the aqueous phase, and approximately 296.2 lbs of VOCs were removed from the vapor phase (Tables 3 and 4). Since the start of the IRM system, approximately 774.6 lbs of VOCs have been removed by the DPE system.
The full report is here and is over 6 MB. Smaller files with report sections are available as well:
Text Figures Tables Lab Reports Data Usability Summary Monitoring Well Purge Logs
OFFSITE - "Operable Unit 3" (OU3) - Neighborhoods down hill from the EPT Site
As described in the 2010 section below, The Record of Decision for OU3 was released in October 2010. It contains none of the extra steps or follow-up testing requested by the affected neighbors. The only testing to be performed will be testing of the exhaust at the top of the 25-foot venting stack to be placed at the Turner Place end of the 300-foot replacement section of sewer on East Spencer Street - shown in blue in this diagram:
Karen Cahill's early-June 2001 update:
* OU No. 3 Remedy: Emerson anticipates starting the remedy implementation beginning mid July 2011, pending NYSDEC review and approval of 90% design and the permitting process.
The detail diagrams of the Sewer and Vent system are here. There are homes along the section of sewer being replaced which had very high test results. We hope that the excavation of the current sewer and installation of the venting system will, in fact, reduce the toxic vapors intruding in these homes. We sincerely doubt that homes further up the hill will be positively affected by the sewer replacement. That the mitigation systems in all the Phase I - Phase V neighborhoods are slated to remain indefinitely suggests strongly that little progress is expected. That the DEC accepted a plan which calls for NO testing other than at the exhaust from the vent stack is incomprehensible and a slap in the faces of all of us who listened to DEC's explanations of how new and untested all this effort was and remains. "We've never done anything like it before, but we will declare it a success (our final step) before the plans have even been reviewed." A more honest answer might have been, "We've spun our wheels here for so long, we simply HAVE to move on."
WSP (Emerson’s Consultants) Release “90 PERCENT DESIGN” Document for Sewer Work
Dated July 12, 2011, WSP released the “90 PERCENT DESIGN” Remedial Design Report for “Operable Unit No. 3” (The South Hill neighborhood below the Emerson site.) It is a collection of many documents:
The full document is here.
The text sections are here.
Figures 1-3 are here.
The “Design Drawings” are here.
The Construction Quality Assurance Project plan is here.
The Health and Safety Plan is here.
The Community Air Monitoring Plan (CAMP), revised July 15, is here.
The document spells out the various steps to be taken to excavate about 300 feet of existing sewer from the bottom of Turner Place (Manhole No. 9) down East Spencer Street to Manhole No. 17. The sewer would be replaced with a new sewer, surrounded by “highly permeable granular material”, into which a perforated pipe would be installed, with a single exhaust stack located near the NYSEG gas installation, to release the vapors from the sewer bedding.
The stack would be approximately 25 feet in height, with a wind turbine on the top. Neighbors are concerned that the vent stack is at the height of many of their homes’ windows. That the vapors from the vent stack would be any higher or lower in concentration than the exhaust from the existing mitigation system stacks is not clear, but there would be testing of the stack exhaust on a regular basis until the overall levels are known.
It is distressing that the “remedial action” doesn’t include any testing to see if the new sewer actually reduces (remediates) the toxin vapors which are present in the East Spencer Street area. The “Remedial Objectives” for this project are to address the three pathways identified for the potential migration of vapors from the sewer lines, including:
“(1) along the sanitary sewer lines;
(2) along the residential sanitary sewer laterals; and
(3) within the vertical and horizontal planes of porosity (fractured bedrock) surrounding the sewer lines.” (page 1)
Without in-home air testing, and testing of the sub-slab vapors under the affected homes, there is no way of knowing that any of these remedial objectives will have been met.
CITY DELAYS GRANTING EASEMENT FOR E. SPENCER SEWER WORK
reported online in the Ithaca Times, July 27, the Ithaca City Board of Public Works received a petition from East Spencer Street neighbors asking the City to delay granting of an easement required by EPT to proceed with the sewer work. They heard pleas from neighbors about the quality of the air, asking for tests to confirm that the sewer "remedy" would not make things worse. Tellingly, one of the WSP consultants remarked that the emissions from this proposed PASSIVE stack would be "nothing" compared to the emissions for the many existing ACTIVE vent stacks which are part of the 59 mitigation systems already in place in the lower South Hill neighborhoods. (The vent stacks were tested in 2008, with distressing, but seemingly "legal" results.)
The BPW passed a resolution adding a testing stipulation to the Easement agreement. A similar resolution was passed soon thereafter by the City Administration Committee - Ithaca Times report here. On Monday, August 1, the City Community Advisory Group met and discussed this issue as well, making changes to the proposed stipulation and agreeing to finalize wording to be submitted to the Common Council for their meeting August 3. The Council spent over an hour discussing the matter but decided to table the matter, to get more information from the DEC. (Ithaca Times report here, Ithaca Journal report here.)
MORSE-EMERSON SITE HISTORY
THROUGH THE 20th CENTURY
Morse facility on South Hill expanded through its first seven decades,
with the most significant and lasting development in power transmission
equipment for industrial and automotive applications: drive chains,
timing chains, sprockets, gears and combinations in various housings
for front-wheel and four-wheel drive systems. The plant layout and
functions are suggested by the "Sanborn" map shown below
- a 1929 map updated to the early 1960's.
Activities included metal stamping, punching, grinding, milling,
heat-treating, oil-quenching, parts washing and product assembly.
Other operations started in the 1960's and 1970's included copper
and cadmium plating, and wire drawing. Many of these processes require
the use of "cutting oils" which must be removed from the
pieces after the process. The removal steps involved a variety of
solvents including mineral spirits, Freon, 1,1,1-trichloroethane,
TCE, and tetrachloroethane. While TCE use was discontinued in 1977
or 1978, peak usage was reported to be about 1200 gallons per week.
map of Morse Chain Site, early 1960's- for a printable version,
awareness and concerns about carcinogenic effects of the various
lubricants and solvents were not as developed in the mid-20th century
as they are today. However, the Morse facility, like many other
industrial and military sites across the country, became the focus
of attention as neighbors reported odors, and strange colors and
oil slicks in water running downhill from the plant.
Some of the problems found are documented in correspondence between
Morse employees and local and State health officials. Many of these
documents have been collected by Walter Hang of Toxics Targeting,
oils used in processing the metal parts were found everywhere -
coating the finished parts and dripping off the pieces of scrap
and shavings which were hauled in bins from the plant to recycling
centers. PCBs were found in this oil, and as our knowledge of the
problems with PCBs grew, so did concern about the oil runoff from
The use of chlorinated solvents as degreasing agents (to remove
the oil from the metal) increased in an attempt to limit the spread
of the PCB-laden oil. However, as it was learned that some of the
active agents in these solvents themselves presented problems, efforts
were made to reduce their use.
volumes of metal, cutting oils, solvents, and water that moved through
the plant site are large. The amounts of metal scrap and the oil
it was treated with are the subject of ongoing discussions between
Morse staff and County Health officials, and the solvents used and
the water taken in and discharged by the plant are detailed in the
1981 application Morse filed for a discharge permit.
||Water Flow Schematic, submitted by Morse Chain as part of State
pollution Discharge Elimination System (SPDES) Permit Application,
Sept. 30, 1981
Map submitted as part of SPDES Permit Application, showing location
of Outfall Discharges. A "Google Earth" view of these
locations may be viewed here.
The locations are:
- uphill from the top of South Cayuga Street,
- below West Spencer Street, near the intersection of Wood and South
1987, TCE was found in oil that had been taken from the surface
of the large fire reservoir on the plant site. Further tests disclosed
the TCE was present in the reservoir water as well.
to the "Record
of Decision" issued by NYSDEC in December, 1994, these
steps were taken over the next years:
EPT notified NYSDEC of the discovery of TCE in oil skimmed off
the surface of an underground fire reservoir. At this time, EPT
hired Radian Corporation to prepare a preliminary environmental
assessment to address TCE contamination in the fire reservoir
and to investigate whether TCE had impacted groundwater.
part of this work, the reservoir was emptied and cleaned using
high pressure water and five monitoring wells were installed.
Samples were collected of the groundwater from those wells, soil,
surface water and sediment from Six Mile Creek, and seeps. This
sampling showed local groundwater was contaminated and that the
fire reservoir was likely a source.. The study also detected petroleum
hydrocarbons in soil taken from the railroad ditch.
1987: The site was added to the New York State Registry of
Inactive Hazardous Waste Disposal Sites.
1988: EPT signed a consent order with the NYSDEC for a remedial
investigation/feasibility study (RI/FS) and remedial program at
1990: Radian Corporation submitted the RI. This information
was used to evaluate interim remedial measure (IRM) alternatives
and to complete the Feasibility Study (FS).
1991: EPT entered into a consent order for an IRM.
1991: EPT finished construction of a groundwater extraction
and treatment system (henceforth referred to as "pump and
treat system") to operate as an IRM prior to completion of
1991: NYSDOH collected air samples from homes near the Morse
site. Based on these samples, the NYSDOH requested and EPT agreed
to install vadose zone monitoring wells to assess the potential
for impacts adjacent to the site.
1992: The Fire Reservoir was rehabilitated and put back into
service. Cracks in the concrete were patched and a liner was installed.
1994: EPT completed a pilot test using the Xerox Two-Phase
Vacuum Extraction system, which was initiated in October 1993.
Pilot test objectives included: evaluating system effectiveness
for removing VOCs from the soil, dewatered bedrock, and groundwater;
comparing system performance to the pump and treat system; and
evaluating the benefit of supplementing or replacing the pump
and treat system with two-phase vacuum extraction for remediation.
pilot test results showed that the two-phase vacuum extraction
system outperforms the pump and treat system. The two-phase vacuum
extraction system removes greater quantities of groundwater, has
higher VOC removal rates, and has a greater zone of influence.
1994: Four vadose monitoring wells were installed and will
be sampled on two occasions. This investigation will be completed
concurrently with the monitoring program for the remedy selected
by the PRAP. Should the need for further remediation or other
mitigation be identified it will be evaluated as a component of
the operation and maintenance program for the site.
UNDERSTANDING IN THE 21st CENTURY
Morse facility on South Hill seemingly escaped significant environmental
notice during the first few years of the 21st Century. The April
1, 2003 NYS DEC listing of Hazardous Waste sites considered
the plant site to be "Inactive", having reclassified it
to an official status of "4" - "Properly closed -
requires continued management". The document's Assessment of
Environmental Problems stated "A plume of volatile organics
emanating from a concrete tank (referred to as the fire water reservoir)
is a threat to the surrounding environment. The low volume pump
& treat system currently in use is helping to lower the groundwater
containment levels." The report also stated "The remedy
(operation of the two phase extraction system) is performing properly
and is effective."
groundwater extraction system continued to be used, and results
were monitored and readings from one well (MW-3-31, located East
of the top of South Cayuga Street, between the Fire Reservoir and
the NYSEG Substation) are summarized in this
February 2004 report prepared by Radian. The readings vary wildly
from season to season and year to year: for TCE, summer readings
(in micrograms per Liter) were:
1996: 6900 1997: 1100 1998:
82,000 1999: 260 2000:
43,000 2001: 78,000 2002: 28,000
These readings are all relative to a NYS Target Cleanup Objective
of 5 micrograms per Liter.
Within 2003, the last year reported, the results varied significantly
March: 20,000 June: 21,000 August:
5800 November: 28,000
After over a dozen years of groundwater extraction, levels were
still very high and showing little sign of abating.
May of 2004, Walter Hang, President of Toxics
Targeting, Inc. held a Press
Conference below the Morse Plant discussing the first of two
he would send to Emerson and to the NYSDEC, referencing many historic
documents and maps his firm had collected and prepared. The
attention Mr. Hang's actions drew helped to spur a variety of actions,
many of which are continuing. The extensive documentation he attached
identified many issues which still have not been addressed by the
responsible parties and State agencies.
response to the concerns Mr. Hang raised, a group of South Hill
residents signed a letter
dated May 25, 2004, to the heads of the NYS DEC, US EPA, NYS DOH,
and to the Mayor of Ithaca, requesting that the agencies report
to the public on their responses to his points and that they press
for actions for mitigation, research into how far the toxins have
spread and the need for health studies.
June 15, 2004 Emerson issued this "Public
Notice" to S. Cayuga Street and Spencer Street Residents
describing 8-hour canister tests to begin on June 16 with the installation
of monitoring points to sample vadose zone gas. They concede
"We are working closely with the state to remedy a situation
that was present when Emerson purchased Morse Chain in 1983.",
but contend "these response actions are adequate and in compliance
with the NYSDEC Record of Decision."
first reply received by the South Hill residents was a letter
(dated June 16, 2004) from Assemblywoman
Barbara Lifton indicating the she and her staff had taken the
initiative to contact the various parties and would try to organize
a meeting with the public.
the first part of 2004, Emerson engaged Environmental Strategies
Consultants LLC to perform vadose zone tests on and near the EPT
facility. Their proposal for this plan was dated January 16, 2004
and approved by the NYS DEC on May 13, 2004. The samples were taken
on June 17, 2004, and this
report of the results, from ESC's Scott Haitz to Carl Cuipylo
of NYSDEC, is dated July 7, 2004. Roughly half the samples taken
showed TCE well above the relevant standards.
Public Meeting was scheduled for August 4, 2004. On August 2, both
NYS DEC and NYS DOH churned out their replies to the May 25 letter
from South Hill residents. It took 10 weeks, but we had both replies
and a Public Meeting.
from Mary Jane Peachey, Regional Engineer, discussed the agency's
response to the EPT situation, including the development and distribution
of a "Public
Information Session" announcement, acknowledged the consideration
and ongoing review of the site classification for possible revision
(back) to class 2, based on the "new data" being presented,
reported that homes within a certain area would be tested for indoor
air quality, and that NYS DEC would work with NYS DOH to determine
if mitigation systems would be required.
from Gary A. Litwin, Director of the DOH Bureau of Environmental
Exposure Investigation, reviewed the site history: in the late 1980's
and early 1990's investigations showed that on-site groundwater
was contaminated with volatile organic compounds. These were attributed
to the fire reservoir and seemed to decrease significantly as the
plume flowed away from the source, and that these levels had decreased
"significantly" since groundwater treatment began in 1991.
He also discussed the testing of 10 houses in the lower South Hill
area, and reported that "soil vapor intrusion" of various
site-related contaminants was found at some of the homes, but that
"health effects were not expected at the levels found."
[One of the sites had an indoor TCE level of 46 ug/cm^3!]
Mr. Litwin went on to explain how some tests required by the
1994 Record of Decision were never (successfully) performed, but
that EPT had installed new vapor wells on South Cayuga and South
Geneva Streets, and results from these well tests "indicate
the need for additional soil gas monitoring and indoor air sampling
of nearby residences."
Litwin goes on to state: "We do not plan to conduct any health
studies specific to this site. The data collected to date do not
indicate that people in the area are being exposed to chemicals
from the site at levels that would be a health concern. In the absence
of significant exposure, adverse health effects are not anticipated."
His letter has a four-page NYS DOH "Frequently Asked Questions"
document on "Soil Vapor Intrusion" attached.
Power Transmission (EPT) also prepared a Notice
for the "Public Information Session", with a two-page
"Fact Sheet" relaying their view of the site history and
recent "soil gas" investigations. They will prepare a
work plan involving indoor and sub-slab air testing, and the installation
and monitoring of additional groundwater monitoring wells. These
tests should combine to determine what additional "investigation
activities" may be necessary." "Since indoor air
sampling results may vary from season to season, it may be necessary
to sample some of the structures on more than one occasion."
Public Meeting was fragmented both in terms of time and location-
there were two sessions: one at the hotel in the afternoon and another
at the hotel in the evening. An "alternate" meeting with
various State officials was also held in the (Borg Warner Room of
the) Public Library in the afternoon. Emerson released their plan
to test 32 homes very close to the plant. Homeowners in other neighborhoods
were not pleased, but held out hope that the State agencies reviewing
the plans would force expansion of the area. The Ithaca Journal
report on the meetings is here.
On August 31, 2004 DEC Engineering Geologist Carl Cuipylo sent this
(with 16 pages of attachments) to Scott Haitz (ESC Project
Director), responding to August 2, 2004 Indoor Air Assessment Work
Plan.. Mr. Cuipylo criticizes the detection limits used in
the June 2004 testing as being too high and requests that ALL the
volatile organic compounds (VOCs) detected in test be included in
the reports to provide information about the interference that other
compounds may be causing. He states that the locations to
be sampled need to be expanded, and that comprehensive testing of
the ambient air and subslab (or subsurface in the absence of a slab)
test most be performed. The attachments include the NYS DOH
"Indoor Air Sampling & Analysis Guidance" (08/01/01),
"Indoor Air Quality Questionnaire and Building Inventory"
forms, "Substructure Soil Gas Sampling" instructions,
and the NYS DEC "Guidance for the Development of Data Usability
September 20, 2004, the Ithaca Department of Public Works released
by Tom West, Assistant City Engineer, to South Hill Residents on
subsurface soil investigations performed August 11, 2004, showing
that samples from the Cayuga Street embankment, soil, and water
all reflected compounds below cleanup standards. Among the
chemicals found were Tetrachloroethene, Toluene, and Chloroform.
dated November 20, 2004, from Carl Cuipylo (DEC) to Scott Haitz
(ESC) reviews the July 28, 2004 Supplemental Off Site Investigation
Work Plan. He specifies inspection and repair of several suspect
wells, and requests certain new wells into the "unconsolidated
overburden", as well as tests of the seep behind 123 South
Hill Terrace, the seep at 514 South Cayuga Street, the cistern at
the upper end of South Cayuga, and of the artesian well behind 212
Wood Street. He refers to "the persistent elevated concentrations
of contaminants remaining in the on site groundwater and those
found in the off site vadose zone and nearby residences."
letter drew this November 12 response
from Derek Chase (EPT) agreeing to most of the DEC points, but refusing
to investigate the artesian well as it is "beyond the study
November 24, James Burke (DEC) sent this letter,
accepting the response by EPT to their review and indicating that
DEC will test the artesian well and sample some wells of particular
Ithaca Journal carried this article
on December 14, detailing the discovery of rusted 55-gallon drums
which had contained methyl chloroform on the wooded hillside below
the south end of the EPT plant, not far from the Morris Heights
home of the resident who reported the drums. A DEC engineer reviewing
the site said the barrels appeared to have been there for "quite
some time, tens of years". Apparently, the "due diligence"
steps that Emerson performed in reviewing the property they purchased
weren't entirely diligent. One wonders why there have been no soil
vapor tests performed on the properties in Morris Heights.
February 25, 2005 this Letter
from the DEC "Site Control Section" was sent to EPT, with
notification of the plant site's reclassification from 4 to 2 (Significant
Hazard to Environment).
from James Burke (DEC) to Derek Chase (EPT), dated February 28,
2005, calls for expansion of the indoor air study area to include
areas west of Spencer Street, including "the area bordered
by Albany, Wood, Plain and Elmira Roads." A second letter,
dated the same day, calls for more comprehensive reporting of monitoring
well data, including all analytic sampling from 1995-present.
slides for the March 3, 2005 public meeting reviewed late 2004
and early 2005 activities. Phase I and II results show need for
Phase III. Site reclassified from 4 to 2 "based on indoor
March 11, 2005 Letter
from ESC to DEC details plans for testing the VOC emissions related
to the operation of a sub-slab depressurization system at 126 South
Hill Terrace", to "evaluate the potential affect on ambient
from Derek Chase (EPT) to James Burke (DEC), dated March 30, 2005,
details the results of the additional Ground Water test wells tested
on Feb. 25, claiming that these results (as well as the prior air
sample results) show that "there is no technical basis for
expanding the current study area at this time."
from James Burke (DEC) to Scott Haitz (ESC), dated April 5, requests
changes in the proposed Preliminary Onsite Remedial Investigation
Work Plan. More detail is desired, especially involving those
places to be tested and their relation to areas identified in prior
studies. ESC is instructed to use a lower detection limit
for TCE (0.25 ug/m^3 rather than the 0.82 ug/m^3 used in Phase I
and II. Mr. Burke also comments, "The statement that
the 2-phase system is 'containing' VOCs cannot be confirmed presently
due to the lack of a historical offsite monitoring network".
12, 2005 Letter
from James Burke (DEC) to Brian Silfer (ESC) about the DEC and EPA
review of the "Drum Recovery / Soil Sampling Report";
asks that this report be incorporated in the "onsite investigation"
EPT has proposed for other purposes.
May 4, 2005, Ithaca's Common Council passed a resolution calling
for full disclosure (by Emerson and Borg Warner) of all toxic substances
known to have been used in the plant, and of all spills of such
substances. For the text of the Resolution, see pages 26 and 27
of the Council
Minutes. The Ithaca Journal article on the meeting is
(May 11, 2005) from Scott Haitz (ESC) to James Burke (DEC) reports
the Feb. 2005 sampling results for offsite GW monitoring wells around
the EPT facility, which found no significant levels of any chemicals
of concern. Retests in April 2005 and additional wells
tested then also showed no significant concentrations of any chemicals
of concern. EPT proposes more wells at the uphill end of South
Cayuga Street and also proposes to conduct an electrical resistivity
(ER) imaging geophysical survey with dipole arrays of electrodes
spaced 3 meters apart.
(June 2, 2005) from James Burke (DEC) to Derek Chase (EPT) regarding
the March 2005 proposals for Aquifer Testing and GW Evaluation of
the Remediation area. Mr. Burke acknowledges that there will
be some value to the proposed pump tests, but feels it will be necessary
to review all site data to properly understand the effectiveness
of any proposed changes to the recovery system. He states,
"A major issue is the lack of any one time assessment of all
possible data collection points. The Department has put together
a snapshot of the site based on data from different time frames
and although the Department can achieve a reasonable picture of
site conditions, it is uncertain how accurate this picture is or
how conditions change over time with relationship to one another.
This site lacks comprehensive periodic monitoring. Although
several of the wells in the immediate area of the extraction wells
have been monitored regularly, there is no periodic monitoring over
the entire site and affected off site areas from which to evaluate
trends over time." He also rebukes EPT for considering
the fire reservoir to be the sole source for the
on site groundwater contamination.
(June 21, 2005) from James Burke (DEC) to Derek Chase (EPT) regarding
the Electrical Resistivity (ER) tests EPT has proposed. DEC
wants more test points on the plant site itself. Mr. Burke
also reminds EPT that previously-requested detail for monitoring
wells on and off the site property still has not been received.
(also June 21, 2005) from James Burke (DEC) to Derek Chase (EPT)
regarding the expansion of the air test study area. Mr. Burke
states, "Through negotiation and counter-proposals, agreement
has been reached in regard to the resampling of specific homes,
an expansion into additional homes, and a vapor point installation/sampling
project west of Geneva Street." As for EPT's contention
that no further home tests are needed west of Spencer St., he says,
"That monitoring wells in the western neighborhood showed no
detectable levels of site-related VOCs cannot be used as definitive
proof that vapor intrusion is not an issue. It is one piece
June 21, 2005) from
James Burke (DEC) to Derek Chase (EPT) regarding the May 11th proposal
for tests in and around the R&D ("Service") Building
at the top of Turner Place. He states that the proposed tests
"will not sufficiently define or evaluate groundwater quality
downgradient from the R & D Building" . He requests
that GW levels be included in data for all sampling events, and
that the "seep" north of the building be analyzed and
included in the R&D report.
Public Meeting was held June 22, 2005 to discuss the results from
the first Phase II indoor air tests and to announce the expansion
of the test area for Phase III, adding homes north of Hillview Place
along both sides of Turner Place, both sides of South Hill Terrace,
and on the "uphill" portion of the 100-block of East Spencer
the summer of 2005, It was announced that Emerson would hire consultants
to study the "Electrical Resistivity" of the areas below
the plant, to try to identify various features under the surface.
Assessment", released on December 13, 2005 (links to document and components of it below), ESC reviews various maps and previous environmental
reports to try to piece together the history of operations in the
various buildings. "The solvent TCE, was reportedly used
to clean metal parts and scrap metal in conveyor type vapor degreasers
located on the ground floor of the main plant building (Building
4 - 507 Degreasing Department). Only one of three areas requiring
"oily soil remediation" was treated to a point that it
met applicable standards. SVOCs and PCBs were found in the
soil remaining after various corroded drums ("discovered"
in Dec. 2004) and other pieces of scrap were removed. Activities
once performed in various sections of the plant (mostly no longer
used) include solvent degreasing and recovery, copper and cadmium
plating. One degreasing using was the "source of an unknown
amount of solvent released to the sanitary sewer system", though
its exact location is unknown. Oil leaking from scrap was
captured in scrap loading area but there were discharges which were
detected in the South Cayuga St. sewer and in the outcrops along
West Spencer Street. There was a "Cyanide Room Drainage Trench",
and acid pickling tanks. There were coal piles and four "below
grade oil quench pits" which are no longer in service, though
a fifth quench oil pit is still in use. Various underground
storage tanks are no longer in use and have been closed in accordance
with NYSDEC regulations. Many of the aboveground storage tanks
still remain in service, but ten tanks, including a 100,000-gallon
fuel oil tank, have been removed. Potential migration of chemicals
from offsite sources (including Therm, NCR/Axiohm, and various other
spill sites) is also reported. Test samples in the Axiohm
disposal area show high levels of TCE, cis-1,2-DCE, vinyl chloride,
SVOCs and metals. 21 specific "Areas of Concern"
throughout the EPT site are detailed, as are the sewer lines down
Turner Place and South Cayuga Street, and "seven potential
migration pathways" identified on old maps. ESC states
that their August 2005 tests suggest that the R&D building (built
on top of a former City Reservoir) is no longer an Area of Concern.
You may view or download:
The full document (12.5 MB)
Figures (including map of Areas of Concern)
Environmental Database Report (The names of databases reviewed)
EDR Radius Map - Findings (Details on spills and incidents)
Government Records Searched
GEOCHECK Physical Settings Source Records
Sanborn Map Report
EDR Historical Topographical Maps
from EPT presentation at the Jan. 25, 2006 Public Meeting.
Overviews were presented on the various investigations performed
during 2005, including R&D air and slab tests, GW tests, the
Geophysical Survey, the Onsite Assessment results, and the expansion
of the Study area for the Phase IV testing: homes on lower Turner
Place, Pleasant Street, and East Spencer St.
of plan to investigate soil surrounding the two sanitary sewer
lines running down Turner Place from the EPT site - one called the
1878 Line and the other called the 1979 Line. There would
be 24 borings just to the west of each of the lines, spaced about
100 feet apart, with soil samples analyzed in the field for VOCs
using a photo ionization detector and then shipped to a lab for
from ESC to DEC reporting the results of Nov. 18, 2005 vadose zone
tests performed along the "NCR sewer" line which runs
downhill on the east side of the plant site. The highest values
found were for TCE with a reading of 477 ug/m^3 at the downhill
end, near where the line runs to South Aurora Street, and 536 ug/m^3
at the uphill end where it enters the EPT site.
March 3, 2006, ESC released a report
of results from their testing of the former "R&D Building"
on the EPT site, at the top of Turner Place. In tests performed
in September 2005 and in test performed in January 2006, TCE and
PCE were found in all tests in all locations. The Indoor air tests
would justify installation of a mitigation system under the 0.8
ug/cm^3 TCE threshold now being used by EPT. The report includes
maps of the sampled locations, and detailed results of the tests.
EPT first announces that it is sending letters
to South Hill Residents, informing them that EPT has voluntarily
lowered the threshold for the Indoor Air test level of TCE needed
to qualify for a mitigation system. They will now offer systems
to any home where any Indoor Air test has found a TCE level of 0.8
micrograms per cubic meter. On March 10, they sent out offers
of mitigation systems to those homeowners newly-eligible under
the revised threshold.
May 10, EPT sends letters
to those homeowners to whom mitigation systems have been offered,
offering to help pay for the electricity used by the ventilation
fans used by those systems. The payments will be made monthly, in
the form of checks for $12.00 payable to NYSEG.
May 19, ESC released a notice
to Turner Place Residents stating the their proposed work plan
to investigate the Turner Place sanitary sewer lines has been approved.
The work will involve drilling soil borings in the public rights
of way to test whether historic releases of site related compounds
have occurred from these sewer lines. The work was performed during
the week of June 5, 2006.
4 Test Results -
from James E. Burke, NYS DEC - May 25, 2006
response to your email of 5/19/06:
The Phase IV samples were taken from residential structures during
the approximate time period of February 20 to April 19, 2006. EPT
typically will receive results from the lab within one month of
sampling. The results are then validated, which can take another
2 to 3 weeks. Once EPT receives the validated results, they will
review them internally and then send to the State for review. Our
review should normally be completed within 2 to 3 weeks of receipt
of validated test data from EPT. Draft homeowner letters are then
prepared by EPT and sent to the State for review and comment. Once
final agreement is reached on the content of the letters for a residence,
they are then sent to the homeowners. The entire process can take
upwards of 3 months from the time of sample collection to the time
the letter is sent to the homeowner. The draft bill requires that
the homeowners receive results from the Responsible Party (RP) within
thirty (30) days of receipt of validated results by the RP. The
State will work with EPT and all other RPs to meet this goal.
This Phase has been slightly delayed due to discussions between
the State and EPT on the content of the Phase 4 homeowner letters.
Please note these discussions are focused solely on the wording
and content of the letters. It should not be speculated that the
delay in sending the letters is related to the nature of the Phase
4 results. There is currently a conference call being scheduled
in the next 1-2 business days with EPT and the State to resolve
The current work at the site includes the Turner Place sewer investigation;
preparation of final geophysical investigation and well aquifer
pump test reports; preparation of the final Onsite Assessment Work
Plan by EPT; and subsequent proposed modifications to the onsite
treatment system by EPT to improve capture of groundwater contaminants.
Please call me at 315-426-7550 with any questions, or email at email@example.com
. Thank you."
first copies of Round 4 Test Results were received June 8, and have
been added to the SHIP
Database. Our ability to understand and explain what's going
on around us is greatly improved by the collection and organization
of the results for all the properties in the neighborhood.
Please consider sharing your results. If you'd like to contribute
results you have received, please contact
have received reports of an even higher subslab TCE reading among
the houses tested for the first time. This was true for the 2nd,
and 3rd rounds of testing as well: the further down the hill they
test, the higher the sub-slab readings found. Please continue to
monitor the SHIP
Database for the latest results and updated maps.
- July 2006 ESC Documents Available in Library Archive
Letters and a few of the attachments of a flurry of correspondence
from James P. Bulman of Environmental Strategies Consulting LLC
(ESC - the consulting firm retained by Emerson to assist in handling
the investigation into the site toxins) to James E. Burke of NYSDEC
have arrived at the Tompkins County Public Library Archive. We have
copied portions of them, and they are available here as Adobe PDF
documents. (Many of the letters contain responses to NYSDEC requests
- those NYSDEC documents do NOT appear to be available in the archives.)
16, 2006 letter Re: Semi-Annual Progress Report - Response to NYSDEC
This document discusses a May 8, 2006 NYSDEC letter providing comments
on the Semi-annual Report for July 2005 - January 2006. NYSDEC had
recommended adding 9 new and 4 additional wells to the list of extraction
and monitoring wells "routinely" sampled and reported
semiannually. The sampling events were scheduled for December 2005
(to be included in the July 2006 Semiannual Report) and again in
July 2006. We have yet to find any of these reports in the Library
also commented on the "elevated levels of VOCs significantly
above State Standards", which "persist in many of the
on-site wells, including:
- Extraction Wells 1, 2, and 3
- Monitoring Wells 2, 3-31, 3-100, 3-150."
these levels remain so high after so many years of operation of
the VOC removal system suggests that the system simply isn't doing
the job that was intended and expected. Many of the current documents
address attempts to improve extraction levels, and to learn more
about the continuing movement of the toxins through the many pathways.
16, 2006 letter Re: May 8, 2006 NYSDEC Correspondence -
Response to NYSDEC Comments March 10, 2006 Proposed Supplemental
This document discusses a May 8, 2006 NYSDEC letter providing comments
on the proposed supplemental geophysical survey work plan for the
EPT site (a document apparently dated March 10, 2006.) NYSDEC asserts
that there may be more zones than the eight areas identified by
ESC as likely "water bearing zones" which are also "hydraulically
conductive." There is discussion of the resistivity measurement
techniques which will be needed to produce three-dimensional models
of the "major conductive zones, which exhibited resistivity
signatures and shapes consistent with potential water-bearing fractures
on site (7A, 2A, and 12A/2D) and offsite (6F, 10A, 9C, 11B, and
11E), [which] will be further evaluated using closely spaced ER
survey lines oriented in a grid around the area where each major
conductive zone was identified."
also states that "following the completion of the supplemental
geophysical survey, Emerson will develop a work plan, which will
include 1 to 3 exploratory bedrock borings to confirm the supplemental
ER image results." "The fracture-like anomalies will be
the focus of the confirmation borings."
discussions require some knowledge of the results of the Electrical
Resistivity Studies (ERS) performed during the summer of 2005. Some
of the relevant documents are these:
19, 2005 Report from Forrest Environmental Services, Inc.,
which discusses (in 9 pages of text) the ERS results, and specifies
(on the last page) the many "conductive anomalies" which
were identified, and suggests that these may be saturated fractures.
2005 Results from Environmental Strategies Consulting are
best put into context by the map on page 2 (Figure 2) which shows
the location of the various test lines, and then shows the colorful
(but seemingly inscrutable) results generated by the tests along
each line. (This is a big file and will download slowly, but the
results can help with understanding the discussions in the ESC
report of the same date, listed next.)
31, 2005 Report from Environmental Strategies Consulting
attempts to explain the results of the ERS tests and to draw conclusions.
The Summary (on the last page) states:
geophysical survey results indicate that five major conductive
zones are located along the northeast and southwest portion
of the EPT site. No major conductive zones were identified in
the immediate vicinity of the current remediation area downgradient
of the fire water reservoir, which was identified in 1987 as
the source of the TCE release.
The results of the geophysical survey also demonstrate that
groundwater migration at EPT is controlled by the orientation
of bedrock structures, including bedding plane fractures and
vertical joint sets. Groundwater flow through the bedrock, as
indicated by the conductive anomalies, is confined to relatively
well-defined, discrete water-bearing zones that correspond to
the secondary porosity of the rock. In the area directly downgradient
of the remediation area where affected groundwater is found
in wells that are not near any significant water-bearing anomaly,
the flow is likely controlled by the amount of horizontal bedding
plane fractures and, thus, the terms stress relief, transition,
and lithologically controlled zones ( i.e., "B", "C",
and "D" zones ) are useful for discussing the distribution
of affected groundwater. However, it is clear from the geophysical
results that the partings alone are not controlling the migration
of groundwater over other portions of the site and a horizontally
zoned conceptual model cannot be used to generalize the hydrogeologic
framework of the site."
16, 2006 letter Re: May 8, 2006, Correspondence NYSDEC March
20, 2006, Geophysical Survey - Response to NYSDEC Comments
This document discusses a May 8, 2006 NYSDEC letter providing comments
on the ERS geophysical survey investigation report dated October
31, 2005. The critical nature of correct siting of the exploratory
borings is discussed, as is the need for correlation with existing
well data. NYSDEC Comment 3 (presumably in the May 8, 2006 correspondence)
Department is keenly interested in the interconnectedness of the
features identified to date, and the preferential migration pathways
beneath and around the Emerson Power Transmission Facility. We
intend to do a thorough review of upcoming Environmental Strategies
submissions. A knowledge of what information upon which a given
conclusion is based will expedite the review process as well as
the decisions made regarding remediation of impacts on the surrounding
22, 2006 letter Re: Aquifer Testing Summary and Design Modification
document summarizes the "aquifer testing" performed by
ESC at the EPT facility in February 2006. The test scheme, seemingly
under discussion since the previous summer, involved pumping quantities
of water from various spots on the plant site and measuring the
degree to which water levels changed in the different Monitoring
Wells. Different technical methods were used to analyze the drawdown
data for the highly-fractured upper portion of the "B"
zone bedrock (where the flow is assumed to be mainly through the
fractures, acting as if "porous media") and for the less
fractured bedrock where the flow is the results of primary and secondary
porosity, resembling non-porous media. Maps of the wells and a diagram
of the geologic cross-section through which the test wells run are
3, 2006 letter Re: Response to Comments - May 8, 2006, Correspondence
regarding Onsite Assessment Report (December 13, 2005)
This letter was accompanied by a table listing the products that
are currently or have been used at the facility. The table is considered
"business confidential" and was not released to the public.
Their general description of such products is:
primary materials used by EPT are steel, cast iron, and plastic.
Other materials used by EPT include coolants, detergents, aluminum
oxide, paints and thinners, ammonia, tumble media, nitrogen, carbon
dioxide, oxygen, helium, kerosene, diesel fuel, and cutting, quench,
and punch oils. Natural gas is used to heat the facility. Propane
is used to fuel forklift trucks, and diesel fuel is used to fuel
the facility's tractor."
is made to the industrial chemical use inventory that was part of
the 1981 SPDES
permit application, but Emerson claims that it does not have
a complete list of chemicals used by the former Borg Warner facility.
There are also references to an outdoor drum storage area and to
a "perennial stream" originating near Ithaca College and
extending through the EPT site. ESC disputes the need for further
remediation for petroleum hydrocarbons.
"Comment 7" is quoted:
location of onsite facility storm, sanitary, process and utility
lines, as well as sumps, discharge structures, etc. should be
investigated as potential pathways for pollutants."
#24 (the former NCR building) is now considered an "Area of
Concern" (AOC) based on the indoor air tests performed in December
"Comment 16 " is quoted:
detail conceptually how the seven potential migration pathways
will be further investigated."
pathways is more than we'd been led to believe existed. ESC says
the investigations will include soil vapor sampling, soil sampling,
and groundwater sampling.
NYSDEC "Comment 17" is quoted:
has submitted two letter reports, dated, 2/13/06 and 4/25/06,
detailing indoor air testing at the EPT facility. The results
from those tests indicated that VOCs are present in the facility
subslab and indoor air at elevated levels for most locations sampled.
The results from all subslab samples taken during both testing
events requires that these locations be considered as AOCs
that will require further investigation as potential source areas
of contamination. It is noted that several of these sites do correspond
to previously identified AOCs. THE NYSDOH is currently reviewing
the indoor air quality and subslab results from these sampling
events, and comments on this will be provided under separate cover."
Strategies Consulting LLC has been calling residents to request
permission to access their property for additional rounds of Electrical
Resistivity testing, involving more probes spaced more closely,
to try to get a more detailed study of the geological features of
the area, including the various fractures through which contaminants
could travel. There will be transect lines along South Hill Terrace,
Hillview Place and East Spencer Street as well as in yards downhill
from homes on the Western side of of the 500-block of Turner Place,
with work scheduled for the last week of July 2006. A sample letter
from ESC is here.
Power Transmission has issued a "Site
Update" dated July 19, 2006, and received by mail from
ESC on July 22. The single-page document addresses:
- Phase IV Indoor Air Testing - 26 homes were tested, 2 have
been offered mitigation. Results will be submitted to NYSDEC and
NYSDOH in August 2006. [That this round of tests found a home with
the highest subslab TCE test reading yet encountered is NOT mentioned.]
- Turner Place Sewer Investigation - "22 soil borings
were installed along the two sanitary sewer lines and 25 soil samples
were collected for laboratory analysis. Results to be submitted
to DEC and DOH in "early August 2006."
-Supplemental Geophysical Survey - to begin during the week
of July 24, performed along public "rights-of-ways" and
on "selected residential properties" to "further
characterize the subsurface geology and ground water flow pathways",
for a report to DEC in October 2006.
- Remediation System Modification - additional extraction
wells and new treatment equipment to modify the existing groundwater
remediation system at the fire reservoir site. To be finished in
the fall, with a report submitted to DEC in November 2006.
final sentence of the update states "All documents relating
to the ongoing investigation in Ithaca may be reviewed, as they
become available, at the Tompkins County Public Library, 101 East
Green Street, Ithaca, New York." ESC and EPT have (to their
credit) made some letters available recently - see below - but recent
documents from DEC and DOH have not been made available at
July 28, 2006, the Report
and associated map
detail the results of soil tests performed along Turner Place June
6-8, 2006. Some of the samples are listed for depths as shallow
as "0.5 - 2 Ft." and others are as deep as "6 - 8
Ft." There are many chemicals sampled and we see the same wide
variations in test values that we've seen in the house air tests.
The highest TCE levels are at the intersection of Columbia Street
with Turner Place. This correlates with some of the higher sub-slab
TCE readings in the homes above and below the west side of the intersection.
intersection is also the spot where the overloading of the storm
sewer system has been most evident. During heavy rains, the manhole
cover near the intersection levitates with water that the sewer
cannot contain. The ongoing Aurora Street sewer project is supposed
to remedy this, by connecting a 24" diameter sewer line to
the Town of Ithaca line which comes down Aurora Street. This new
line will start at the intersection of Columbia and Aurora and run
down to the Wastewater Treatment facility behind Aldi's. The existing
14" diameter line will continue to serve the "local"
neighborhood needs. With the high TCE readings noted in the "NCR
Sewer line" running from the EPT plant property to South Aurora
Street, one can only wonder how much TCE has been carried through
these sewer lines, and where it has settled.
of Ithaca Common Council Resolution- August 2, 2006
City of Ithaca Common Council unanimously approved a "RESOLUTION
IN SUPPORT OF BLANKET MITIGATION AND EXPANDED HOME TESTING IN ALL
NEIGHBORHOODS AFFECTED BY CHEMICALS FROM THE EMERSON POWER TRANSMISSION
SITE". The Resolution
calls for NYSDEC and NYSDOH to push the "responsible parties"
to provide blanket mitigation of affected neighborhoods and to provide
wider areas of testing at all times of the year. Council Members
Maria Coles, Mary Tomlan, and Shane Seger were instrumental in moving
this resolution through the process and we thank them for their help
and hope that the statement will have positive effects.
September 1, 2006, this Report
details the findings of the tests performed in 26 neighborhood homes,
including 15 homes not previously sampled. Based on the results
and the NYSDOH decision matrix, 3 homes were designated "No
further action", 21 homes will "require further monitoring"
and two homes have been offered mitigation systems. Details
are provided for test results for all Phase IV tests, as are questionnaires
and household inventory forms.
from "WSP Environmental Strategies LLC" (the new name
for Environmental Strategies Consulting LLC) detailing the extraction
well tests conducted January to June 2006, during which period the
average system uptime was 80%. The system removed 170,558
gallons of groundwater, including a half-pound of VOCs from the
aqueous phase and approximately 31 pounds of VOCs from the vapor
phase. This brings the estimated total of VOCs removed by
the system to approximately 350 pounds since the start of system
operation. TCE levels ranged from 38 to 32,000 ug/L, cis-1,2-DCE
from 15 to 8,100 ug/L, trans-1,2-DCE 89 to 92 ug/L, vinyl chloride
4.6 to 1,200 ug/L and methylene chloride 48 to 640 ug/L. The
report states "Since September 2004, when ESC Engineering began
managing the 2-PHASE ™ extraction system, the concentrations
of VOCs in these wells have exhibited no consistent trend."
of "Packer testing and sampling" performed onsite August
14 - 23, 2006. The tests hoped to explore the nature of open
horizontal bedding plane fractures present in extraction wells EW-1
and EW-3 at approximately 52 feet below the top of each well.
"The packer testing results indicate that the bedding fracture
identified at 52 feet is a transport pathway for groundwater below
the current remediation. The results suggest that the horizontal
bedding plane fracture has been intersected by a vertical conduit
(joint set), which allows affected groundwater to migrate downward
to the bedding fracture plane... the upper C-zone and B-zone wells
are not in direct hydraulic connection with the deeper extraction
and Map from WSP describing the properties they intend to test
as part of Phase V. (The letter refers to "Table 1"
which is not part of this copy.) They will test 18 properties that
were sampled once during Phase IV. Two properties have been
offered mitigation but have not accepted the offer and will be tested
again. One home (Property 97b) will be sampled for the first
time, as will the Ithaca City Court building and the Ithaca Police
Department headquarters. [Subsequent discussions supposedly
added the Police garages to the list - they are located across from
the IPD main building, below the "creek side" row of homes
along the 100-block of East Spencer St.]
Work Plan submitted by WSP. "The additional subsurface
information gained from this investigation is necessary to complete
the design upgrades to the remediation system at the site.
The proposed scope of work involves installing and sampling six
open boreholes in areas hydraulically upgradient, cross-gradient,
and downgradient of the fire reservoir and three shallow B-zone
wells immediately surrounding the reservoir."
Geophysical Survey - A 225-page report prepared by WSP, with
all manner of theory and discussions of the additional Electrical
Resistivity tests, with results displayed with various colorful
graphs. Fields notes and tables of points along the various
lines are included, as are notes of anomalies found. Unfortunately,
there is no discussion about what all this might mean in terms of
changes to be made in testing or remediation efforts.
V Indoor Air Tests for Ithaca Police Department, City Court
results from the Phase V tests performed in January and February
2007 are finally being released and received. Among those reports
are results for the Ithaca
Police Department and City Court Building, and the Garage/Sheds
across the street. Site related toxins were found in both sites,
with the highest levels in the sheds, which are located between
the "creek side" of the 100-block of East Spencer Street
and Six Mile Creek. These results complete tests along one path
from the plant site to the creek, with high levels of TCE found
up and down the path. That these toxins have moved roughly 1500
feet down the hill shows just how wide an area of South Hill the
plumes involve. Expansion of the testing area is needed to find
the "perimeter" of the plume, but significant actions
to stem the toxins at the source (the plant site) are the more critical
Air Tests show more and more TCE
"Outside" Ambient Air tests performed as a "background"
reference for the ongoing indoor air tests are showing more and
more TCE in the air we breathe. As these tables
show, finding detectable levels of TCE in the "Outside"
air was the exception in the results from Rounds I, II, and III,
which were performed before most of the mitigation stacks were installed
in our neighborhood. However, the results from Rounds IV and V show
that detects are now the rule, not the exception. Given the number
of stacks now exhausting TCE into our air, this is not entirely
a surprise, but it IS distressing to think that we've moved the
TCE from being largely trapped underneath our homes out into the
air that's around us and streams into our homes. Is this really
Areas of Concern listed in the Onsite
Assessment of the EPT site dated December 13, 2005, are finally
getting some attention as Walter Hang, President of Toxics
Targeting, Inc., has posted this letter to DEC Commissioner Grannis. Maps of the Areas of Concern at the EPT plant site
are in PDF versions here: Map
2-3. That neither the NYS Department of Health nor the
NYSDEC have organized any public meetings to discuss the many serious
problems described in the Assessment is an "Area of Concern"
in itself. Mr. Hang's News Release is discussed in the April
26, 2007 Ithaca Journal. Thank you, Walter, for sounding the
1, 2007 Ithaca Journal carries a trio of stories (as well as
download links for many source documents) discussing the history
of problems at the Wallace Steel site. The huge quantities of metal
scrap (from Morse Chain, NCR, Ithaca Gun and Smith Corona) which
passed through the Wallace site were generally coated with oil,
some of which leaked off during transit and during storage and handling
at the dump site. Reports of leaks of oil into and onto the water
are cited. (Unfortunately, this article is no longer online.)
Mayor Carolyn Peterson asks DEC for EPT Cleanup of Contamination
May 23, 2007, Ithaca Mayor Carolyn Peterson sent this letter
to DEC Commissioner Grannis, regarding the EPT site and stated,
"This serious and ongoing affront to the health and safety
of our community must receive the fullest extent cleanup as is possible.
I understand there are a number of mitigation possibilities that
can improve the indoor air quality of the affected homes. Mitigation
should be installed forthwith; enough testing has been done. Secondly,
source cleanup is essential through removal of the contamination.
Thirdly, an immediate and thorough investigation of the former Wallace
Junk Yard should be conducted immediately." Mayor Peterson
also offers her office as a source of help for any public outreach
the DEC cares to make. Thank you, Mayor Peterson!
pressures EPT for Unified Remediation Plan; Expanded Area for Home
Properties added to Study Area, including some large rental
Phase VI Area (yellow shading):
detailed response from the DEC to EPT's May 3, 2007 Supplemental
Remedial Investigation Work Plan is a 12-
page document. The first 5 pages are a May 31, 2007 letter
from Gregg Townsend (DEC Regional Hazardous Waste Remediation
Engineer) to Derek Chase of EPT, spelling out modifications
that EPT is to make to their proposed Work Plan. The next
6 pages are relevant excerpts on "REMEDY SELECTION"
from the "DRAFT DER-10 Technical Guidance for Site Investigation
and Remediation, December 2002". The last page is a color
map (right) showing the proposed expansion of the home testing
area for "Phase VI" - expanding the area eastward
up Prospect, Pleasant, and Columbia Streets, and Hillview
Place, to their intersections with South Aurora Street. This
is a significant expansion of the area being tested, and seems
to have been dictated by the high levels of TCE found at test
points on the EPT site near South Aurora Street, east of the
existing study area.
response to this DEC letter was issued on June 20, 2007, in
the form of a 5-page
letter from Sheila M. Harvey, Esq., of Pillsbury Winthrop
Shaw Pittman LLP, listing points of agreement and points of
contention with the plan revisions requested by DEC. EPT does
NOT want to drill and take borings in the bottom or sides
of the fire reservoir. EPT wants to go (very) slowly on testing
in the proposed Phase VI area, and EPT feels "it is not
physically possible to meet the deadlines in the specified
timeline" spelled out in the DEC letter.
click on the map for a PDF version.)
Report of Phase
V Indoor Air Tests Released
June 15, 2007, WSP released the full report of the "Indoor
Air Assessment Phase V Sampling Event". While the results of
testing at the Ithaca Police Department and City Court building
were made public earlier, this report has full details for all
the tests performed in Phase V. The search for the "clean
perimeter" of the toxins plume does not seem to be making much
progress - almost every TCE test performed in this round on properties
also tested in Phase IV had higher results this time. The
Police properties and City Court building were the only properties
added for Phase V. The full report is now online and split into
segments for easier retrieval: Main
Visit Questionnaire and Product Inventory Form, "Data
Usability Summary Report" (cover page only), Summary
Tables Part 1, and Summary
Tables Part 2.
Releases EPT "Supplemental Remedial Investigation" Work
Environmental Strategies has submitted a Supplemental
Remedial Investigation Work Plan, dated June 29, 2007, on behalf
of Emerson, responding to the changes requested by the NYSDEC in
a letter dated May 31 (below). The report is lengthy, attempting
(as requested by NYSDEC) to coordinate more of the intended activities
into single planning documents. The Plan discusses:
- soil borings and investigations into the identified "Areas
- further investigation of the Fire Water Reservoir,
- installation of additional monitoring wells and more exploratory
borings to continue the geophysical surveys,
- soil vapor testing in the Phase VI area (for which NYSDEC
has requested indoor air testing), and
- soil vapor testing in "groundwater discharge" areas.
addition to the Work Plan text (discussed above), WSP released various
Topographic map of the EPT Site Location,
Areas of Concern, showing intended soil borings, soil vapor points,
and test locations,
- Former and Proposed vapor point locations, downhill from the plant,
and Proposed vapor point locations, uphill from the plant, along
the "NCR Sewer",
- Proposed Exploratory Boring and B-Zone monitoring Wells, most
downhill from the plant,
- Identified Structural Features and points for further exploration
last map shows some of the fractures and other structures that were
identified through the electrical resistivity studies performed
last year, showing "fracture trends" that seem to correspond
with some of the locations of the higher TCE readings found in indoor
Leaders and Residents ask DEC to Maintain Scope of Work and Timetable
residents, including officials of the City, Town, and County, Landlords,
and other concerned citizens signed a letter
sent July 17, 2007 to NYS Department of Environmental Conservation
Commission Alexander "Pete" Grannis to request that he
not accept any delays or reductions in the scope of his agency's
landmark proposal to investigate and clean up 25 "Areas of
Concern" involving the contaminated Emerson Power Transmission
facility. "We are extremely grateful that Commissioner
Grannis recently took a firm stand on cleaning up hazards associated
with Emerson's chain factory, but we asked him to oppose the company's
attempts to reduce the effectiveness of the DEC's plan of action,"
said Walter Hang, who wrote the letter.
allows Emerson six extra weeks for "field work" and initial
the letter sent by community residents and local leaders to the
DEC (see below), requesting that the DEC not allow the timetable
to slip, the DEC has extended the deadline for finishing the "field
work" steps of the Remediation Investigation Work Plan by six
weeks, from August 31 October 12. Subsequent deadlines have
been similarly pushed back. The DEC letter is
here, and a "Question & Answer" summary the DEC
prepared is here.
An item of great concern is the DEC's apparent willingness
to accept the curbside soil vapor testing to be performed in the
Phase VI expanded test area as an indicator of which homes in the
area to choose for indoor air testing. We feel this is very
ill-advised. The many well and soil vapor tests that have
been performed throughout the study area have shown very little
correlation to the indoor air test results inside the structures
away from the curb. The DEC's ongoing "temporal" testing
has shown great variations even within single homes where multiple
test points have been installed. The area's residents are most affected
by the air inside their homes - not the vapor in their curb lawns!
Testing should be performed on all homes in the affected
area, and blanket mitigation should be offered to all homeowners
in neighborhoods where homes have had TCE air detects. The
results of one or two tests cannot be justified as a basis
for a declarations of "No Further Action".
Soil Vapor Testing Report - South Hill Elementary School",
dated August 21, 2007, details how "low concentrations of certain
VOCs were detected in the soil vapor samples collected on the school
property. Trichloroethene (TCE) was detected at concentrations ranging
from 0.492 to 8.36 ug/m^3." The report presents results from
tests along and around the "NCR sewer", which runs down
S. Aurora Street from the former NCR site further up South Hill,
to support the theory that the toxins found on the school grounds
originated at NCR, not at Morse or Emerson. We are told that
follow-up testing (involving 18 canisters of air taken from the
school's sub-slab and from crawl spaces, but NOT from classroom
or office space) has been performed, but further details or results
have not been released.
Remedial Investigation Report Released by WSP/EPT
on the 2007 tests and studies performed by Emerson's consultants,
WSP Environmental Strategies has been released, and an electronic
copy was provided to us by the NYSDEC - Thank you! The report
discusses the findings of tests performed in and around the "Areas
of Concern" on the EPT site, the continuing investigations
into the "Fire Water Reservoir" (see Figure
8), the evaluation of the bedrock under the plant (which extends
into our neighborhoods) and the results of soil vapor tests throughout
the study area, including the Phase VI expansion area, bounded by
Columbia Street, Turner Place, Prospect Street, and South Aurora
Figures 13-14) There are discussions, tables of results,
maps, and "conceptual block diagrams" of the bedrock.
attention is placed on the "NCR Sewer", which has been
the site of high TCE readings where it runs along the EPT plant
site and South Aurora Street. These new readings confirm the path
of pollution along Aurora Street, Columbia Street, Turner Place
and down to East Spencer Street. The readings also confirm the suspicion
that TCE has been leaking all along from the Fire Reservoir area
down the hill into our neighborhood. We look forward to analysis
of the raft of new material by the representatives of NYSDEC and
NYSDOH at the next Public Meeting.
first significant event of the new year was the Public
Meeting with representatives of NYSDEC and NYSDOH, held January
24 at the Ithaca Town Hall. With the release of the exceptionally
high test results from November 2007, the most immediate task-list
discussed at the meeting included the re-testing of those properties
with the high results. These re-tests were underway when two properties
on East Spencer Street were damaged by fire, so the tests were conducted
Work Plans were released at the time of the public meeting:
Sampling and Analysis Work Plan (January 23, 2008) and
Manhole Assessment Work Plan (January 24, 2008).
These plans address concerns raised during 2007 and at the public
meeting. No explanation has yet been given for the 18,900 ug/m^3
TCE reading found in the MH-4 manhole at the corner of Turner Place
and Columbia Street - they'll test manholes along Turner Place and
East Spencer Street. The vent sampling will test the vents
installed on two homes on East Spencer Street to measure toxin content
of the exhausted air. How much can be learned from two short tests
on one day at two properties is not clear. The ambient
air TCE levels along Spencer Street seem to be rising and increasing
been released for the various re-tests of ambient air levels that
were conducted in early February 2008, after extremely high test
values were detected in November 2007 - they were sent to the property
owners, Postage Due. These results seem to be more
in line with the earlier, lower-level readings, but the levels,
both inside "mitigated" homes and in the ambient air around
them, are creeping up.
Remedial Investigation Report, dated April 4, 2008 was sent
by WSP to the DEC which kindly sent a copy to us. The Report is
comprehensive - this portion includes almost 250 pages at over 10
MB PDF size - but seems to have few details on likely remediation
MORSE KNEW IN '72
May 7 edition of the Ithaca Journal contains the front page
report, and their web site has the report
and links to relevant documents. Morse officials knew of the presence
of TCE in their fire water reservoir in August 1972. The online
links include one to the 10-page
complaint Emerson filed against Borg-Warner (the parent of Morse
Chain when it was sold to Emerson in 1983) alleging "fraudulent
misrepresentation of the condition of the plant at the time of its
EVALUATING CLEAN-UP OPTIONS
April 25, 2008, WSP released
the 133-page "Supplemental Remedial Program / Alternatives
Analysis" (SRP/AA) for the Morse site. It contains the usual site
history and topographic map we've seen before, but talks more of
their theories of what they're finding, presents rehashed summaries
of earlier test results, and suggests some possible ways of remediating
four of the "Areas of Concern" on the plant grounds.
The following files have this documents sections, but these have been superseded by the "Revised Final" SRP/AA document, released September 23, 2008, below.
Full (133-page) Report - 11.6 MB PDF
text sections (Pages 1-96) - 609 KB
1 - Site Location Topo Map
2 - Aerial View of Site
3 - Conceptual Site Model
4 - Geologic Cross Sections
5 - Vapor Migration Model
6 - Soil Vapor Migration Pathways
7 - Quarterly Groundwater Results
8 - Site-Wide Groundwater Results
9 - Fire Water Reservoir Groundwater Results
10 - Proposed Supplemental Exploratory Boring Locations
11 - Proposed Exploratory Well Locations
12 - Building Layout
13 - Proposed Boring Locations: AOC 1, 15, 24
14 - Proposed Boring Locations: AOC 4
15 - Proposed Additional Soil Vapor Point Locations
The DEC reviewed the April version of the SRP/AA, and asked for revisions. The WSP/EPT response to those requests is here.
The "Revised Final" SRP/AA document, released September 23, 2008, reflects the negotiations between WSP, EPT, and the DEC.
Full (128-page) Report - 10.6 MB PDF
text sections (Pages 1-96) - 279.7 KB
1 - Site Location Topo Map
2 - Aerial View of Site
3 - Conceptual Site Model Beneath Fire Water Reservoir
4 - Geologic Cross Sections
5 - Distribution of Affected Groundwater (B-Zone)
Fig 6 - Distribution of Affected Groundwater (C-Zone)
Fig 7 - B-Zone Groundwater Contour Map
Fig 8 - C-Zone Groundwater Contour Map
Fig 9 - Conceptual Model - Vapor Intrusion along Turner Place
10 - Soil Vapor Migration Pathways
11 - Quarterly Groundwater Results
12 - Site-Wide Groundwater Results
13 - Fire Water Reservoir Groundwater Results
14 - Supplemental Exploratory Boring Locations
15 - Proposed B-Zone and C-Zone Extraction Well Locations
16 - Building Layout
17 - Proposed Boring Locations: AOC 1, 15, 24
18 - Proposed Boring Locations: AOC 4
19 - Proposed Additional Soil Vapor Point Locations
has proposed steps to "enhance" the groundwater extraction
system around the Fire Water Reservoir (FWR) - the results of the
system's operation over the last 12+ years are unimpressive.
DEC is continuing limited testing in some of the homes in the Phase
VI expansion area. Full Soil Vapor Intrusion testing, if they decide
it is needed, will take place during the upcoming heating season.
TOXINS RELEASED THROUGH VENT STACKS: HIGH - BUT UNDER NYS STANDARD
September 23, 2008 Vent Sampling Report is not much reassurance to those of us who have complained that the toxins levels in the ambient air - especially along East Spencer Street - have been getting higher. The report details the procedures used to determine that the output from the stacks, each tested three times during a day in July, 2008. Though the TCE levels detected, measured in micrograms per cubic liter, are almost all higher than the NYS indoor air standards, that's not the standard that is applied here. WSP gets to use "the 1.0 pound per hour (lb/hr) control requirements stated in 6NYCRR (Part 212.)" - from page 2 of the report. A pound per hour - for toxins normally measured in micrograms per cubic meter! This allows them to conclude (on page 6 of the report) that "emissions from mitigation systems are not a source of concern for TCE and PCE in the ambient air in the South Hill community."
While they cite stack emission rates of all the site-related volatile organic compounds (VOCs) tested to be no higher than 0.1101 pounds per hour, at that rate, it takes less than 10 hours for that vent stack to spew out a POUND of these toxins for which air standards are measured in micrograms per cubic meter. The data appendix with all the results is here, but it's a 24 MB file.
IMPORTANT CORRECTION ISSUED AUGUST 16, 2011
TOXINS RELEASED THROUGH VENT STACKS: MUCH BETTER THAN ORIGINALLY REPORTED
Vent Sampling Report was released September 23, 2008, but the problems with some of the data presented were not acknowledged by WSP until August 16, 2011. As discussions heated up on the proposed "remedial step" of installing a vented sewer along East Spencer Street, concerns developed about the many stacks in the neighborhood and the fact that the WSP report suggested that pounds of toxins were being released daily through the SSDS vent stacks. This is the explanation sent to us for the source of the error:
A review of Table 3 (Mass Emission Rates) shows the reported emission rates are incorrect (actually lower by 10,000). First, the conversion from ug/m3 value to g/m3 was incorrect by a factor of 1,000 and the conversion factor (CF) used to convert cubic feet per minute (cfm) to meters cubed per second (m3/s) for use in developing the emission rate via EPA Method 18 was incorrect by a factor of 10 (original calculation spreadsheet used a value to 4.719 x 10-3 and it should have been 4.719 x 10-4 The corrections of these two conversion factor errors are incorporated into a revised Table 3 (Attached).
The corrected "Table 3" is here. Please note that the originally values reported were 10,000 times higher than what they now believe to be coming out of those stacks.
PUBLIC MEETING DISCUSSES
PROPOSED AMENDMENT TO 1994 "RECORD OF DECISION"; SEWERS CONSIDERED MAIN PATH
Interested neighbors, City officials, and members of the media met with representatives of the NYS Department of Environmental Conservation (DEC) and the NYS Department of Health (DOH) on in two sessions on March 5th, to discuss the proposed amendments to the 1994 "Record of Decision" and the steps proposed to "upgrade" the clean-up efforts on the Emerson Power Transmission (EPT) site.
The agency officials expressed their belief that the "infamous" Fire Water Reservoir still needs to be cleaned up, but the main source of the soil vapors now intruding into neighborhood homes seems to be the sewers. EPT admits that TCE was dumped into the sewers running down South Cayuga Street and Turner Place. Test readings along those sewer lines remain high. Test readings along Columbia Street and East Spencer Street are also high, but the toxins in those lines also include contaminants from the Therm and NCR/Axiohm sites.
The remediation of the sewers is expected to be proposed in the next months and will be the subject of an additional Public Meeting. Expansion of the areas in which homes and the soils under them will be tested will also continue. Susan Shearer of the NYS DOH commented on testing the vapor exposure pathways into the various neighborhoods: "We follow wherever the data takes us and we haven't stopped yet." Tests have been performed along South Aurora Street already and released to the homeowners. Results of preliminary tests along the sewer lines from Therm have just been received and are being evaluated.
An Adobe PDF version of the slide show presented by the NYS officials is here.
The Amendment document is here - a 3.4 MB PDF. Public comments in written form are invited, and should be sent to the DEC's Gregg Townsend by March 20. We are grateful to Gregg for providing us with these documents as well as the slide show copy.
The Remedial steps discussed in the Amendment are limited to changes ON-SITE at Emerson. They have already "upgraded" the groundwater extraction system which has been attempting to remove contaminants from the Fire Reservoir Area since the early 1990s. A plan is in place to better evaluate the system's effectiveness. The document notes that
"A TCE concentration of 43,000 parts per billion (ppb) was detected in a sample collected from this area as recently as July 2007. (The corresponding groundwater quality standard for TCE is 5 ppb.)"
- So there is clearly a LONG way to go toward remediating this area.
In Situ Chemical Oxidation (ISCO) is proposed for the initial cleanup of the "Former Department 507 Degreaser" area groundwater, followed by Monitored Natural Attenuation (MNA). This is proposed with various tests needed to determine if the groundwater is really being cleaned up and to what extent nearby groundwater is affected. The contaminated soils in this area simply will be capped in place, with various restrictions implemented to limit access and use, to avoid disturbing the encapsulated contaminants.
Other areas on the plant grounds will be capped with asphalt to try to keep the contaminants from reaching the ground surface, while some areas which now have "a weathered petroleum product" will be excavated and removed. Basements of on-site buildings into which the contaminants have been leaking will be sealed and caulked. Building 24 (once home to some operations of the PRI and other non-profit groups) will be abandoned and access to it restricted.
Though the Amendment document discusses (on page 6) the residual contamination of the Turner Place and South Cayuga Street sewers and acknowledges the adverse impact on air quality in neighboring homes, no solutions or proposed remedial steps are presented. The document states:
"Remedial actions to address the off-site migration of contaminated soil vapor will be selected by the NYSDEC following EPT's evaluation of the investigation results and completion of an alternatives analysis."
In other words, real remediation of the toxins "off-site" - in our neighborhoods - is left for discussion some time in the future, even though the "final" SRP/Alternatives Analysis report was released last September (above, in 2008 section).
Discussions of test results along the sewer lines coming down the hill from Therm, IC, NCR/Axiohm, as well as Emerson are in this web site's Sewers section.
WSP COMPLETES UPGRADING OF GROUNDWATER TREATMENT SYSTEM
At the end of March 2009, Emerson's Consultants, WSP, released two documents concerning the significant changes made to the groundwater treatment and extraction system in the Fire Water Reservoir area. This is considered an "Interim Remedial Measure" (IRM) and activities supporting it were accomplished before the "final" amendments to the Record of Decision for the plant site were approved. The reports issued are the IRM Construction Completion Report and the IRM Operation, Maintenance and Monitoring Plan. (The OM&M document is about 26 MB - it will take a while to download.)
We are very grateful to Karen Cahill of the Syracuse DEC office for passing along these documents along to us. Ms. Cahill tells us, "This effort was very extensive on Emerson's part and it is anticipated that the addition of the Dual-Phase Extraction system will enhance CVOC removal efficiencies. It will take a few years of monitoring the system and removal rates before any firm conclusions can be drawn, but the first two progress reports are very encouraging."
DEC ISSUES JUNE 2009 "RECORD OF DECISION AMENDMENT "
We are very grateful to Gregg Townsend of the Syracuse DEC office for passing along this document. Very little was changed from the "Proposed ROD Amendment" issued in February and presented at the March 5 Public Meeting. The document was formally approved on June 18 by Dale A. Desnoyers, Director, Division of Environmental Remediation. Some details of the EPT on-site work have not yet been submitted for DEC review, including the "work plan" for testing needed to select the appropriate technology for in-situ treatment.
A "Responsiveness Summary" (Appendix A) has been added to include written comments received from the public and from WSP (Emerson's consultants.) Only the WSP comments warranted even text changes in the document. Comments from others were "answered" with unyielding responses. Consider the comment from Walter Hang (Appendix Page A-4):
COMMENT 12: Abandonment of buildings does not eliminate underlying contamination hazards. The pollution should be removed.
RESPONSE 12: The abandonment of Building 24 is an initial step to insure the protection of human health. As discussed earlier, additional remedial measures (e.g., groundwater extraction and treatment, in situ groundwater treatment, free product removal) will be implemented throughout the plant to directly address contaminant sources.
In discussing ISCO (in-situ chemical oxidation), the document refers to how "the oxidant had been successfully distributed throughout the contaminant plume" (Appendix Page A-3), but the reports of the subsequent test results from the Axiohm site show that several of the test wells there were unaffected by the ISCO treatment. It still remains to be seen if any of the proposed steps for the EPT site will actually reduce levels of toxins present.
Also remaining to be seen are any signs of progress toward proposals for cleaning up the surrounding neighborhoods. The pace of this process is frustratingly slow. The January 2008 Public Meeting suggested that we would see a "Proposed Remedial Action Plan" (PRAP) in "Early April 2008", with "Remedial Action Start" in July 2008. The March 2009 Public Meeting told us that the ROD Amendment would be implemented this summer, but also suggested that the Off-site Vapor Migration effort would have the "Proposed Alternative Identified/Public Comment" in June 2009. The latest "South Hill Update" says:
The PRAP will be distributed for public review and comment in late August 2009, with a public meeting anticipated some time in September 2009. Upon the close of the public comment period, a final remedy to address the migration of soil vapor into the surrounding
neighborhood will be selected by the NYSDEC in a separate Record of Decision.
Should you wish to read the latest ROD Amendment document, it is online as a single file or in sections:
Appendices A & B
EMERSON ANNOUNCES PLANT TO CLOSE BY SEPTEMBER 2010
On August 12, Emerson Power Transmission (EPT) announced plans to shut down their operation here on South Hill. Most of the 228 current employees will lose their jobs. The facility is over 100 years old in many areas, so it is not the most efficient and up-to-date site for industrial operations. The closure makes consideration of how the plant site is remediated even more important - we've seen how the toxins left behind by a previous operation can become additional expenses for developers and municipalities with the on-going attempts to reclaim the Ithaca Gun site. Simply abandoning the buildings does NOT solve the problems.
Emerson's plans for remediating the South Hill neighborhoods near the plant have not yet been officially announced. We know that extensive clean-up of the sewers and the fill around them is necessary.
EMERSON ON-SITE ACTIONS STILL BEING INVESTIGATED
A "Preliminary Design" investigation into the levels of toxins under and around the EPT Fire Water Reservoir (FWR) was conducted in June and July 2009. The full report is here. Levels of TCE in the water within the FWR (up to 8100 ug/liter) and the groundwater around it (up to 530 ug/liter) remain high. How these findings may change the approach to on-site remediation is not known. A follow-up investigation report was issued on October 2.
The first "Progress Report" for Dual-Phase Extraction System Operation, Maintenance and Monitoring was issued October 30. It reports that they estimate almost 50 pounds of chlorinated VOCs were removed from the vapor phase passing through the system, and an additional 23 pounds from the aqueous phase, during the January - June 2009 reporting period.
EPT SITE OFFERED FOR SALE: $3,900,000 FOR 94 ACRES
The three-page sales flyer is here. No mention of the on-going clean-up or the buildings which have been closed to prevent them from exposing any more employees to toxic fumes. It's a lot of land, with ample power, water and sewer. As it's about one-third in the City of Ithaca and two-thirds in the Town of Ithaca, the ultimate use of the site could be subject to various zoning requirements and decisions. Neighbors can only hope that a serious clean-up of the site and the neighborhoods which it affects will be accomplished before new tenants are exposed to the current facility's more toxic "features".
PUBLIC MEETING HELD JUNE 17, 2010
The NYS Department of Environmental Conservation (DEC) conducted the Public Meeting required for discussion of the Proposed Remedial Action Plan (PRAP) for the sewers downhill from the Emerson plant. The DEC provided us with a PDF copy of the "slides" which provide an overview of the discussion. No one is happy with the proposed remedy, but it is felt that any more substantial (and costly, disruptive) steps would be"technically impractical". As the remedy and the expected "Record of Decision" are considered the final steps in the cleanup, there was discussion about how little measurement of the results of the effort is proposed.
The 66 neighborhood homes which have mitigation systems or have been offered such systems would keep them running for protection. No in-home testing of these or any other nearby homes is required or expected. This decision applies only to the homes in "Operable Unit 3" - corresponding to Phases 1 -5 of the initial home-testing. Further work is expected in Phases 6 and 7, extending from lower Columbia Street to Hudson Street. Phase 7 will probably be expanded.
A letter of comments submitted is here. The supporting figures are here.
The “good news” is that some of the hard-working employees of the NYS Department of Environmental Conservation (DEC) have managed to overcome the obstacles of severe budget cuts (results of Albany dysfunction and economic disaster) to finally release a Proposed Remedial Action Plan (PRAP) for the sewers downhill from the Emerson plant. The PRAP specifies removal and replacement of about 300 feet of sanitary sewers along East Spencer Street, starting at the intersection with Turner Place. Vented pipe would be installed along with new sewer line into the sewer trench, to allow any soil vapors to escape.
That’s the only “Remedial” action specified in the PRAP. The mitigation systems already in place would remain in operation. The proposed action will seriously disrupt the residents of East Spencer Street, as well as anyone who normally travels this street. This area contains homes which had high test levels of TCE indoors, but there are dozens of homes with high test levels that are relatively distant from this 300-foot section of street.
EMERSON "OFF-SITE" RECORD OF DECISION RELEASED
The document is here. The DEC seems to fallen back on the relatively UNprotective standard for indoor air TCE contamination still held by the NYSDOH (5.0 ug/m^3), and determined that only the nine mitigation systems installed into homes that exceeded that standard will count in their evaluation of which areas of the hill should be remediated. Because the homes which received those mitigation systems are clustered at the east end of East Spencer St. (mostly - except for the 3 up hill along South Hill Terrace), they feel that only that section of East Spencer St requires remediation.
They're so sure of their theories that they will not test homes for indoor air to see if their theoretical remediation even works.
Homes that met Emerson's "voluntary" mitigation standard of 0.8 ug/m^3 should be glad they got their systems from Emerson, as other homes exceeding that standard, but not having readings over 5.0, will not get help from the DEC. The mitigated homes which didn't hit the 5.0 standard were not considered in determining which areas need remediation. Many other states are more protective of their residents.
The DEC document states: (ROD pp. A-3 and A-4)
It is not necessary to expand the sewer replacement to include areas on Turner Place and South Cayuga Street. Elevated levels of TCE and other VOCs were detected in some soil vapor samples collected along Turner Place and South Cayuga Street, however, based on the soil vapor intrusion evaluation, in conjunction with our overall understanding of the site's geology, the areas within OU No. 3 where there is a potential for exposures related to soil vapor intrusion have been identified and appropriate actions have been taken.
Blanket mitigation within OU No. 3 is not warranted. As discussed in Section 5.2 of the ROD, nine mitigation systems were installed. The data does not support the installation of additional systems.
No further testing of homes is warranted, however it should be noted that the remedy has been modified to include monitoring of the venting system, which will include, at a minimum, testing of the standpipe(s) emissions after the venting system is installed (see response to Comment 5).
The replacement of the 300-foot section of the East Spencer Street sewer line will certainly cause much disruption to a neighborhood that is experiencing upheaval due to the Prospect Street work and the East Clinton Street bridge work. Whether the replacement makes much difference in anyone's indoor air will be left as an exercise for the homeowners - DEC will not require any tests to find out.